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2 European Commission Joint Research Centre Institute for Health and Consumer Protection Contact information IHCP Communication Office Address: Joint Research Centre, Via Enrico Fermi 2749, Ispra (VA), Italy This publication is a Scientific and Policy Report by the Joint Research Centre of the European Commission. Legal Notice Neither the European Commission nor any person acting on behalf of the Commission is responsible for the use which might be made of this publication. Europe Direct is a service to help you find answers to your questions about the European Union Freephone number (*): (*) Certain mobile telephone operators do not allow access to numbers or these calls may be billed. A great deal of additional information on the European Union is available on the Internet. It can be accessed through the Europa server JRC83512 EUR EN ISBN (pdf) ISSN (online) doi: /86037 (online) Luxembourg: Publications Office of the European Union, 2013 European Union, 2013 Reproduction is authorised provided the source is acknowledged.

3 Preface This report was drafted by the Joint Research Centre s Institute for Health and Consumer Protection (JRC-IHCP) in the frame of an Administrative Arrangement (ENV/07/070307/2012/641465/D3) with the European Commission s Directorate-General Environment (DG Environment) and was reviewed by the European Chemicals Agency, DG Environment and the JRC coordination group on unconventional gas. The authors would like to thank those people who contributed to the drafting of this report, e.g. by revisions and suggestions, in particular Andreas Ahrens, Sylvain Bintein, Andrea Iber, Florence Limet, Jeroen Provoost, Minna Sirkiä and Hermann Stamm. This report does not represent the official view of the European Commission or the European Chemicals Agency. It should be noted that this project was not a compliance check or any other formal REACH evaluation of the dossiers/substances analysed.

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5 Executive summary Hydraulic fracturing is a technique that has been applied for stimulation of conventional oil and gas wells in the US since many years. In Europe, the technique has been used in a more limited number of wells, essentially at low volumes in some tight gas and conventional reservoirs. The recent developments in high volume hydraulic fracturing combined with directional/horizontal drilling techniques have made the gas trapped into unconventional reservoirs such as shale formations economically exploitable. In the US, shale gas has become an important energy resource. In the EU, there is limited experience in the use of these techniques and research/experimental drilling activities have been performed in some Member States where shale gas reservoirs are present. In order to understand whether the use of certain substances for hydraulic fracturing of shale gas reservoirs has been registered under REACH, and eventually how the companies are dealing with the registration of such a use, a number of REACH registration dossiers related to 16 substances that may be connected with this specific application have been assessed 1. The list contained all submitted dossiers from 1 st of June 2008 till 16 th of May It should be noted that this assessment is not a compliance check or any other formal REACH evaluation of the dossiers/substances considered. The main outcome of the assessment is that neither hydraulic fracturing nor shale gas was explicitly mentioned in the investigated dossiers. Hydraulic fracturing of shale gas reservoirs was not identified as a specific use for any of the substances and a dedicated Exposure Scenario was not developed by any registrant. However, some of the identified uses in the investigated dossiers may implicitly cover hydraulic fracturing of shale gas reservoirs. Specifically, 26 use names 2 have been considered as potentially relevant for hydraulic fracturing of shale gas reservoirs to different extents and have been investigated. In most of the cases, the use description system implemented in IUCLID Section 3.5 enabled the identification of these uses based on two simple information items: i) the use name as formulated by the registrant; and ii) the Sector of Use (SU) assigned by the registrant to the use name and chosen among several options provided by the European Chemicals Agency (ECHA). Specifically, the selection of SU 2a 'Mining (without offshore industries)' and SU 2b 'Offshore industries' by the registrant allowed a correct interpretation of the use name and consequently the identification of 1 The dossiers were selected and investigated before the launch of the voluntary disclosure initiative by the International Association of Oil and Gas Producers (OGP): 2 REACH requires registrants to provide in the IUCLID Technical Dossier a brief general description of the uses in the life cycle of the substance they manufacture and/or import. ECHA Guidance R.12 and IUCLID section 3.5 provide a harmonized system for describing uses. The current IUCLID version 5.4 includes a free text field for the use name, a free text field for description of the application process and a set of use descriptors (pick-lists) to be assigned to that use. For substances meeting the criteria to be hazardous or considered to be a PBT/vPvB the registrant is obliged to carry out a Chemical Safety Assessment for human health and the environment for each use to demonstrate the risk is controlled. 5

6 the potentially relevant uses. In addition, the registrant often assigned the Process Category (PROC) and the Environmental Release Category (ERC) to the use name in order to characterise the use of the substance in terms of potential occupational exposure and potential release into the environment, respectively. Both descriptors are generic by nature and are meant to cover ranges of exposure conditions but not to address specific details. None of the options provided by ECHA for PROC and ERC are specific for activities related to hydraulic fracturing of shale gas reservoirs. Some of the available options for PROC (i.e. PROC 1 to 4) cover occupational exposure conditions that can be considered as similar to those ones occurring in oil and/or gas fields and may to some extend be used to characterise workers activities related to hydraulic fracturing of shale gas reservoirs as well. On the contrary, none of the available options for ERC is reflecting the environmental exposure conditions associated with an outdoor industrial activity where a substance is intentionally introduced into the environment to perform a technical function. However, it has to be underlined that the use descriptor system implemented in IUCLID Section 3.5 gives the registrant the possibility of creating a specific additional PROC and/or ERC in case the available options are not suitable for the use under consideration. For most of the investigated substances, a Chemical Safety Assessment (CSA) for the environment was not performed by the registrant based on the justification that no hazard was identified for the substance. In one case, the registrant explained the absence of the CSA for the environment based on two arguments that are related to the investigated use (including both oil and gas extraction): i) the ultimate fate of the substance is the produced water that is continuously re-used (i.e. reinjected) in on-shore operations and therefore not discharged; and ii) the amount of chemical that partitions to the oil phase is sent to refinery and is assumed to be consumed during the process and not released. For three substances, a qualitative risk assessment for the environment was provided. In one case it was concluded that the releases from production and use of the substance are expected to be low and the substance presents a very low hazard to the aquatic and terrestrial environments based on data from acute toxicity studies and ready biodegradability tests. In the remaining two cases, the ph-effect of the substance was considered as the only potential hazard for the environment. However, it was concluded that ph is usually adjusted when waste waters pass through a treatment plant. Four substances were addressed by a dedicated CSA for the environment. All these assessments took into account the release of the substance to marine surface waters from off-shore platforms. This scenario may be less relevant for the shale gas case due to the fact that most of the reservoirs in the EU are on-shore and the releases into the environment in on-shore operations may be different from the ones associated with an off-shore platform. Moreover, none of the assessments explicitly 6

7 quantified the potential release into the environment that may be associated with the specific process of hydraulic fracturing. Two models were applied in the investigated CSA for the environment: i) the Chemical Hazard Assessment and Risk Management (CHARM) model and ii) the European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC) Targeted Risk Assessment (TRA) tool. In one dossier, the registrant used the CHARM model to estimate the release into the environment of 'production chemicals' (defined as chemicals that are added to either the injection water or the produced water to e.g. protect the installation and maintain production efficiency). Production chemicals do not include fracturing chemicals. In the CHARM model a scenario is also available, which explicitly includes the use of a chemical in hydraulic fracturing and applies specific algorithms to estimate the release into the marine environment and related exposure concentrations. This scenario refers to an off-shore platform, covers marine surface waters as compartment, does not distinguish between conventional and unconventional reservoirs, and assumes that a large part of the substance that is injected into the well remains in the rock formation and is not released. This scenario may not be fully applicable to the shale gas case but may be considered as a starting point for the future development of a more appropriate scenario covering the possible migration of those chemicals that remain in the rock formation. In addition, it has to be pointed out that the CHARM model is recommended by ECHA and also mentioned by OECD in the Exposure Scenario Document on Chemicals used in Oil Well Production (2012). In this document hydraulic fracturing is mentioned but not addressed by specific algorithms. Moreover, the basic assumption behind the document is that all the chemicals that are injected into the well are recovered in the produced oil and/or water and disposed (nothing remains in the rock formation). The environmental releases are therefore related to the method of disposal of produced water, which is different for off-shore and on-shore sites. This document only refers to oil and gas production from conventional reservoirs and does not cover the production from unconventional reservoirs. This scenario may however be a starting point for the future development of a more specific scenario covering the shale gas case and the environmental fate of those chemicals that do not flow-back but remain in the reservoirs. In two dossiers the CSA for the environment was carried out using the ECETOC TRA tool. In one case the specific ERC suggested by the European Solvent Industry Group (ESIG) and European Solvent Volatile Organic Compounds (ESVOC) in the Generic Exposure Scenario Use in oil and gas field drilling and production operation was applied. This specific default scenario seems to cover the release of chemicals to surface marine waters from off-shore platforms during drilling activities but does not mention hydraulic fracturing operations. However, this scenario may also be considered as 7

8 a basis for the future development of a more appropriate scenario that takes into account the release of chemicals during hydraulic fracturing operations in both off-shore and on-shore sites and explicitly covers the case of unconventional reservoirs such as shale formations. Based on the experience gained during the assessment of the dossiers, it can be concluded that some actions could increase the availability of information on use, exposure and risk management for substances used in hydraulic fracturing of shale gas reservoirs. First of all, the possibility of defining a more specific use name that addresses hydraulic fracturing could be explored by industry. Secondly, the current use descriptor system under REACH may be complemented by an additional ERC covering the case of a substance that is intentionally introduced into the environment to carry out its technical function. Finally, the environmental exposure assessment may benefit from the development of a model that covers the direct introduction of substances into the underground and possible migration upwards. 8

9 Table of contents Executive summary...5 List of abbreviations Introduction Hydraulic fracturing Methodology Findings of the assessment General findings Type of use Sector of Use (SU) Use name Product Category (PC) Technical functions Process Category (PROC) Environmental Release Category (ERC) Exposure Scenario (ES) Chemical Safety Assessment (CSA) for workers Chemical Safety Assessment (CSA) for the environment Conclusions Appendix I Appendix II List of technical functions required in fracturing fluids and examples of chemicals from the literature Template for in depth assessment of registration dossiers of substances that may be connected with the use in shale gas extraction

11 1. Introduction Unconventional gas reservoirs such as shale formations are geological rock formations characterised by very low permeability and porosity, which require specific technologies to make the extraction and production of gas possible and marketable 3. Specifically, shale formations need to be stimulated before wells drilled into them can effectively produce gas. Stimulation is performed by hydraulic fracturing, which means the injection of water, propping agent and chemical additives at high pressure into the wellbore to create fractures and keep them open in order to enhance the rock permeability. Despite hydraulic fracturing has been applied to enhance oil and gas recovery in some conventional wells in the US since the early 1900s, this technique is an absolute requirement for shale gas reservoirs from the initial stage of well production 4. Specifically, it is the combination of hydraulic fracturing and horizontal drilling along with the recent technological advancements that make the exploitation of shale gas reservoirs possible 3. To date, shale gas production has been significantly exploited in the US 3. Estimated reserves of shale gas are present in several European countries, e.g. Poland, France, United Kingdom and Norway 5. In some sites (notably in Poland, United Kingdom and Germany), research and experimental drilling activities have been undertaken to evaluate the reservoirs capacity and test the rate and effectiveness of gas production. In this context, the Joint Research Centre s Institute for Health and Consumer Protection (JRC-IHCP) was asked by the European Commission s Directorate-General Environment (DG Environment) to perform an assessment of REACH registration dossiers of certain selected substances that may be connected with the use in hydraulic fracturing of shale gas reservoirs. This task was carried out in the frame of an Administrative Arrangement between DG Environment and the JRC-IHCP. The REACH registration dossiers refer to a selection of substances, which are known from the literature as being associated with the use in hydraulic fracturing of shale gas reservoirs in various countries with unconventional gas exploitation activities (e.g. the US) and might be used for that purpose in the EU as well. 3 International Energy Agency (IEA) Golden Rules for a Golden Age of Gas. World Energy Outlook Special Report on Unconventional Gas. 4 Broderick J, Anderson K, Wood R, Gilbert P, Shamina M, Footitt A, Glynn S, Nicholls F Shale gas: an updated assessment of environmental and climate change impacts. Tyndall Centre for Climate Change Research, University of Manchester. 5 AEA Technology plc Support to the identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe. Prepared for the European Commission DG Environment &United States Energy Information Administration World shale gas resources: an initial assessment of 14 regions outside the USA, US EIA, Department of Energy, Washington DC: 11

12 The main goal of this task was to understand how industry is dealing with the registration of the use of chemicals in hydraulic fracturing. The assessment has focused on existing information provided by registrants in IUCLID technical files and related Chemical Safety Reports (CSRs) and aimed to: i) identify those uses of the substances that are potentially relevant for hydraulic fracturing of shale gas reservoirs, ii) understand whether those uses are covered in dedicated Exposure Scenarios (ESs) in the CSR, and eventually iii) evaluate how the ESs were developed and the related exposure assessments carried out. It has to be noted that the aim of the project was not to assess compliance of the dossiers or adequacy of the registered uses and related ESs with REACH requirements. The aim of this task was not to conduct any type of REACH evaluation, and the conclusions should not be interpreted to be an indication of the potential (in)compliance of any individual dossier or inadequacy/inappropriateness of the registered uses and ESs for hydraulic fracturing of shale gas reservoirs. The present document reports and discusses the results of the assessment of the selected REACH registration dossiers. Section 2 briefly explains the process of hydraulic fracturing of shale gas reservoirs and Appendix I reports a list of technical functions required in fracturing fluids along with examples of chemicals used e.g. in US and Canada for those purposes. The methodology that has been followed for the assessment of the REACH registration dossiers is described in Section 3, while the template that has been used for the assessment is reported in Appendix II. The main findings are summarised and discussed in Section 4. The conclusions of the work are drawn in Section Hydraulic fracturing The process of hydraulic fracturing mainly consists of the injection of water along with propping agents and chemical additives at high pressure into the wellbore to create and keep open a network of fractures and consequently enhance the rock permeability. The fracturing fluid is initially injected into the formation under high pressure (up to 650 bars). The fluid pressure provokes fractures that grow in width as the injection continues 6. Fractures can extend tens or even hundreds of metres away from the well bore 7. 6 New York State Department of Environmental Conservation Final Generic Environmental Impact Statement on the Oil, Gas and Solution Mining Regulatory Program. 7 International Energy Agency (IEA) Golden Rules for a Golden Age of Gas. World Energy Outlook Special Report on Unconventional Gas. 12

13 20 to 50 % according to IEA (2012) 7 or 30 to 70 % according to GWPC (2009) 8 of the injected fracturing fluid flows back (i.e. flow-back water ), while the rest remains bound to the clays in the shale formation. The flow-back water also contains saline water with dissolved minerals from the shale formation (i.e. formation water ) 9. The flow-back water is collected in pits/tanks and either disposed (e.g. deep well injection in the US) or treated for discharge/re-use (e.g. may be used to fracture another well on the same pad or to re-fracture the same well). The network of fractures created connects the shale formation to the well and allows the natural gas to migrate from the rock pores to the surface. Hydraulic fracturing of shale gas reservoirs is usually combined with horizontal drilling. Fractures are therefore created at set intervals, about every 100 m, along the horizontal well (i.e. multi-stage fracturing ). Stages are fractured sequentially, beginning with the stage furthest away and moving towards the start of the well 9. The common trend is to build multi-well pads with usually six to eight wells (but can be more) drilled sequentially from a single pad 10. Re-fracturing of a well is possible as the production of shale gas tends to significantly decrease after a few years of exploitation 10. The hydraulic fracturing procedure itself is estimated to last from 2 to 5 days per well, including approximately hours of pumping. The flow-back period is estimated to last 2-8 weeks per well and may occur simultaneously for several wells 11. Fracturing fluids are usually a mixture of water, propping agent, and chemical additives, which may represent up to 2% of the whole volume. Appendix I reports a list of technical functions required in fracturing fluids and examples of chemicals that are known to be used in fracturing fluids from the literature (especially in the US and Canada). The composition of fracturing fluids is highly variable and depends on the geological properties of the rock formation on site and the company performing the work. An online national hydraulic fracturing chemical registry called fracfocus 12 discloses the chemicals that are used for hydraulic fracturing in various wells across the US. The information is submitted on a voluntary or regulatory basis by participating companies. It is possible to localize a specific well on 8 Ground Water Protection Council Modern Shale Gas Development in the United States: A Primer. Prepared for the US Department of Energy Office of Fossil Energy and National Energy Technology Laboratory. 9 The Royal Society and The Royal Academy of Engineering Shale gas extraction in the UK: a review of hydraulic fracturing. 10 Broderick J, Anderson K, Wood R, Gilbert P, Shamina M, Footitt A, Glynn S, Nicholls F Shale gas: an updated assessment of environmental and climate change impacts. Tyndall Centre for Climate Change Research, University of Manchester. 11 New York State Department of Environmental Conservation Revised Draft Supplemental Generic Environmental Impact Statement On The Oil, Gas and Solution Mining Regulatory Program

14 a map and check on the chemicals that are used in that specific case. The US House of Representatives published in 2011 a report 13 listing all the chemicals occurring in over 2500 fracturing products used by oil companies in the US from 2004 to This list has been recently updated by the US Environmental Protection Agency in its Progress Report Study of Potential Impacts of Hydraulic Fracturing on Drinking Water Resources 14. Some companies 15 that have been involved in the pilot phase in the EU also disclose the chemicals that have been used in some exploratory drilling sites. For example: Cuadrilla in United Kingdom 16 ; ExxonMobil in Germany 17 ; and ExxonMobil in Poland Methodology DG Environment identified 16 substances that may be connected with shale gas extraction and based on that 782 REACH registration dossiers were selected and sent by the European Chemicals Agency (ECHA) to JRC-IHCP for the assessment at the end of June The selection included all submitted dossiers from 1 st of June 2008 till 16 th of May The list of substances and the correspondent number of dossiers received are reported in Table 1. The substances were chosen based on literature information coming from the US experience with hydraulic fracturing of shale gas reservoirs 15. The in depth assessment has not addressed all the received registration dossiers but has focused on the most relevant ones for each substance, which means on those dossiers where it has been assumed to find most of the information. 13 United States House of Representatives. Committee on Energy and Commerce. Minority staff Chemicals used in hydraulic fracturing. 14 United States Environmental Protection Agency Study of Potential Impacts of Hydraulic Fracturing on Drinking Water Resources. Progress Report. US EPA Office of Research and Development. 15 This work was carried out before the launch of the voluntary disclosure initiative by the International Association of Oil and Gas Producers (OGP):

15 Table 1: Substances selected by DG Environment for the assessment (in alphabetic order) and correspondent number of REACH registration dossiers received by JRC-IHCP from ECHA. Substance name Number of dossiers 2-ethylhexane-1-ol 10 Acetic acid 53 Acrylamide 46 Ammonium sulphate 133 Boric acid 39 Citric acid 22 Distillates (petroleum), hydrotreated heavy naphtenic 21 Distillates (petroleum), hydrotreated light naphtenic 15 Ethylene glycol 83 Ethylene glycol monobutyl ether 7 Glutaraldehyde 2 Hydrochloric acid 120 Isopropyl alcohol 10 Methanol 110 Residual oils (petroleum), hydrotreated 9 Sodium hydroxide 102 Total 782 All the 16 substances were registered by means of a joint submission. For each of them, the assessment has focused on the IUCLID technical file of the lead registrant and the available Chemical Safety Report (CSR). For seven substances the Joint CSR has been considered. For nine substances it has not been possible to clearly identify the Joint CSR, therefore the own CSR submitted by the lead registrant has been considered as the most relevant document. It has to be taken into account that the Joint CSR or the own CSR of the lead registrant may not contain the whole information that was registered by the consortium. Some members may in fact report in their IUCLID technical file as well as in their own CSR some additional information on uses, technical functions and ESs that could be relevant for the purposes of this assessment. This has been verified for five substances. In these cases, one member dossier (including its own CSR) has also been deeply analysed in addition to the lead dossier. It has to be pointed out that not all the received member dossiers have been checked, 15

16 and therefore it cannot be excluded that some relevant information may have been unintentionally omitted. Finally, for one substance two individual submissions have been received in addition to the joint submission. Both submissions registered the substance as Transported On Site Isolated Intermediate (TOSII). Consequently, the information in these dossiers has been considered as not relevant for the purposes of this assessment. The dossiers have been analysed as stand-alone documents based on the information provided by the registrants. Additional information has been retrieved from the literature in some circumstances, when the need of acquiring more knowledge and/or clarify doubts on specific issues mentioned in the dossiers has arisen. A template has been designed to facilitate the assessment. It is included as Appendix II in this report. The template has been used as a working document when examining each dossier selected for this project. Using this template the assessor could easily record the relevant information found in the dossier as well as provide his opinion on the extent to which the information covers the use of the substance for shale gas extraction. The template also contains one column with instructions for the assessor. They represent the criteria that the assessor has considered while analysing the content of a certain dossier and mainly refer to use descriptors that may be associated with extraction operations in oil and gas fields. The list of use descriptors and related codes is provided in specific REACH guidance documents and used by companies to describe in a standard way the uses of the substances within the IUCLID technical dossier and related CSR 19. Specifically, the following criteria have been developed to evaluate whether and to what extent the use may be connected with extraction operations in oil and gas fields: Use names containing the following key words: shale, hydraulic fracturing, fracking, well, stimulation, injection, gas, oil, extraction, drilling, production, mining, on-shore, off-shore, ph regulator, corrosion inhibitor, anti-scaling agent, complexing agent, biocide, surfactant, gelling agent, friction reducer, breaker, solvent. Sector of Use (SU): SU 2a Mining (without offshore industries) and SU 2b Offshore industries are the sectors of use that may encompass the oil and gas extraction industry. Another sector that should be taken into account is SU 3, which generically refers to any industrial use. Product Category (PC): PC 20 Products such as ph-regulators, flocculants, precipitants, neutralization agents, other unspecific and PC 8 Biocidal products are potentially relevant for 19 European Chemicals Agency Guidance on information requirements and chemicals safety assessment. Chapter R.12: Use descriptor system. Version: 2. March

17 hydraulic fracturing of shale gas reservoirs since chemicals with these technical functions are used as additives in fracturing fluids. PC 40 Extraction agents may also be relevant, even if it mainly refers to substances that facilitate extraction of chemicals from matrixes in laboratory activities rather than to substances that enhance oil and gas recovery. Process Category (PROC): there is no specific process category that can be directly linked to the use of a substance in oil and gas extraction operations. However, the injection of fracturing fluids into the well may be considered as a process that occurs in closed/contained systems (e.g. pumps) where exposure for the workers is null, occasional or very low. This exposure conditions may be characterised by PROC 1, 2, 3, and 4. Environmental Release Category (ERC): there is no specific release category that can be directly linked to the use of the substance in oil and gas extraction operations. ERC from 1 to 7 could be used as they refer to industrial activities; however, they consider indoor environments, while the extraction of oil and gas is an outdoor activity. The remaining ERC may be excluded as they refer to professional wide dispersive use of a substance. IUCLID version 5.3 has been used for the assessment of the selected dossiers. 4. Findings of the assessment The main findings of the assessment are reported in the following sub-sections, from 4.1 to Specifically, sub-section 4.1 discusses the general findings while more detailed findings related to the investigated uses (e.g. use name, technical functions) are summarised and discussed in the subsequent sub-sections (from 4.2 to 4.11). The findings have been illustrated as statistics without making reference to specific substance names and/or dossiers as well as company names. 4.1 General findings First of all, it has to be pointed out that neither hydraulic fracturing nor shale gas was explicitly mentioned in the investigated dossiers. Hydraulic fracturing of shale gas reservoirs was not identified as a specific use for any of the selected substances and a dedicated ES was not developed by any registrant. In spite of that, it has to be acknowledged that some of the identified uses and related ESs may be relevant for hydraulic fracturing of shale gas reservoirs and implicitly cover this specific activity. Based on this consideration, these potentially relevant uses have been investigated and results have been reported in the following sub-sections as well as in dedicated Appendixes. 17

18 In total, 26 uses among the registered ones in the investigated dossiers have been considered as potentially relevant for hydraulic fracturing of shale gas reservoirs. These uses have been found in the registration dossiers of 13 out of 16 substances. In most of the cases these uses have been easily identified taking into account two information items: i) the use name as formulated by the registrant; and ii) the Sector of Use (SU) assigned by the registrant to the use name. The use name is required by REACH and can be easily retrieved from a dedicated field in the IUCLID technical file of any dossier. In the received dossiers, the industrial area (e.g. oil industry, mining) or a specific process where the substance is applied (e.g. drilling, oil and gas production) was often part of the use name and this has allowed an easy identification of the majority of the relevant uses. However, in all these cases the registrant never distinguished between conventional and unconventional oil and/or gas reservoirs. In some cases, the use name alone was too generic and not a sufficient criterion to identify the relevant uses in need of deeper investigation. In this context, the presence of SU 2a Mining (without offshore industries) and/or SU 2b Offshore industries as use descriptors has been considered as additional criterion. However, despite SU is part of the use descriptors system recommended by ECHA, the registrant is not obliged to report it and in many cases the registrant either did not specify it or assigned a generic descriptor for industrial and professional use (i.e. SU 3 and SU 22) to the use name in the IUCLID technical file. In these cases, it has been necessary to look over the CSR to find more information and conclude on the relevance of the use (e.g. the ES title or the list of tasks/processes covered by the ES). 4.2 Type of use It has to be underlined that any use of the substance in oil and/or gas fields for drilling and production operations, including hydraulic fracturing of shale gas reservoirs, has to be considered under Uses by workers in industrial settings (i.e. industrial use) and not under Uses by professional workers (i.e. professional use) in IUCLID 5.3. The use of a substance in oil and/or gas extraction activities is clearly related to an individual industrial site, which can be interpreted as an independent point source of releases characterized by a limited number of locations over a certain area and where high volumes of the substance(s) are involved (ECHA personal communication). Conversely, a professional use corresponds to a wide dispersive use, which assumes the presence of many users in the public domain including small, non-industrial companies that deliver services to 18

19 business or private customers 20. A professional use is also by default associated to a local municipal sewage waste treatment plant 20. Among the 26 uses that have been considered as potentially relevant for hydraulic fracturing of shale gas reservoirs, 20 uses have been registered as Uses by workers in industrial settings and 5 uses as Uses by professional workers. It has to be clarified that in four cases the same use name was registered twice in the registration dossier and appeared both as an industrial use and a professional use with different use descriptors (i.e. different SU, PROC and ERC). Even if dedicated ESs were not developed in the available CSR, it has been concluded that the intention of the registrant was to address these uses separately and therefore they have been investigated as such. One use name was registered both as an industrial use and a professional use in the IUCLID technical file but in this case a dedicate ES was developed for the professional use only. In this dossier, the intention of the registrant could not be clearly understood and therefore a definitive conclusion about the type(s) of use could not be drawn by the assessors. In this context, it has to be taken into account that the interpretation of the registrant of the definition of industrial use or professional use may differ from the original meaning given by ECHA in the guidance documents. 4.3 Sector of Use (SU) Despite SU is not obligatory under REACH, one or more codes were typically associated with each use name. Most of the times the SU was reported in both IUCLID technical file and investigated CSR. In one case the codes were different whereas in two cases additional codes were specified in the CSR compared to the IUCLID technical file. Eleven uses reported the SU in the CSR only. In some cases the registrants associated one single descriptor to the use name while in other cases more descriptors were specified for the same use name. In particular, the generic descriptor for industrial uses (i.e. SU 3 Industrial uses: Uses of substances as such or in preparations at industrial sites ) was explicitly associated to a use name eight times while the generic descriptor for professional uses (i.e. SU 22 Professional uses: Public domain (administration, education, entertainment, services, craftsmen) ) appeared five times in the investigated dossiers (which corresponds to the five registered professional uses discussed under sub-section 4.2). As SU 3 is a generic descriptor, it has been assumed that it can also cover the use of the substance as additive in fracturing fluids for shale gas extraction. However, this use would be 20 European Chemicals Agency Guidance on information requirements and chemicals safety assessment. Chapter R.16: Environmental Exposure Assessment. Version: 2. May

20 better described by other available descriptors in the REACH guidance documents such as SU 2a, which refers to Mining (without offshore industries), and/or SU 2b, which refers to Offshore industries. Specifically, SU 2a is the only descriptor available to the registrant to characterise the use of the substance in on-shore mining operations. In this case, it has been assumed that the term mining is meant to indicate any industrial extraction process, including the one for minerals as well as for oil and gas exploitation. SU 2a and 2b were specified seven times and eight times, respectively (sometimes for the same use, other times for different uses). Moreover, in four cases the SU 10 Formulation [mixing] of preparations and/or re-packaging (excluding alloys) was reported, which has not been considered as relevant for hydraulic fracturing of shale gas reservoirs. However, it has to be taken into account that the formulation of fracturing fluids is a side activity that usually occurs on-site in a dedicated blender where individual additives are mixed. Finally, one case in which all possible SU codes (i.e. from 1 to 24) were associated to the use name was also found. 4.4 Use name None of the 26 uses that have been considered as potentially relevant for hydraulic fracturing of shale gas reservoirs contains the word hydraulic fracturing, fracking, shale gas or similar as part of their names. In 22 cases the industrial sector in which the substance is applicable (e.g. Use in oil industry, Use in mining operations ) or a more specific activity/process in which the substance is used (e.g. Use in oil field drilling and production operations, Well stimulation chemicals ) were reported in a generic way in the use name. More specifically, oil was mentioned six times and oil and gas was reported nine times. Gas alone was never reported. Moreover, it was never explicitly stated if the use would refer to conventional or unconventional reservoirs. On-shore and off-shore was specified in the investigated use names once and three times, respectively. Three use names included the technical function of the substance only (e.g. Professional use as corrosion inhibitor ). In these cases, the relevance of the use for hydraulic fracturing of shale gas reservoirs has been judged based on other information items such as the SU reported or the related description of use in the CSR. In one case, both a relevant industrial activity and a relevant technical function were reported in the use name (i.e. ph-regulator, flocculant, precipitant and neutralisation agent, etc (in the mining and off-shore ind. ). 20

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